Privacy statement

This privacy policy applies between you, the reader of this document, and Larato Limited. Larato takes the privacy of your information very seriously. This privacy policy applies to our use of any and all data collected by us or provided by you.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at https://larato.co.uk/terms-and-conditions.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data

collectively all data submitted to or collected by Larato. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies

a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Data Protection Laws

any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR

the General Data Protection Regulation (EU) 2016/679;

PECR

the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Larato Limited, or us

Larato Limited, a company incorporated in England and Wales with registered number 5451360 whose registered office is Larato Limited, The Farm House, Radnage Common Road, Radnage, Buckinghamshire, HP14 4DH, UK;

UK and EU Cookie Law

the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you

any third party that accesses the Website and is not either (i) employed by Larato Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Larato Limited and accessing the Website in connection with the provision of such services; and

Website

the website that you are currently using, www.larato.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
   3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
   4. “including” is understood to mean “including without limitation”;
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This document serves as the privacy notice required under UK data protection law.  It is designed to explain how Larato Limited processes data.
4. This privacy policy applies only to the actions of Larato Limited and Users with respect to the Larato Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
5. For purposes of the applicable Data Protection Laws, Larato Limited is the “data controller”. This means that Larato Limited determines the purposes for which, and the manner in which, your Data is processed.

Data collected

6. We may collect the following Data, which includes personal Data, from you:
   1. name;
   2. contact Information such as email addresses and telephone numbers;
   3. demographic information such as postcode, preferences and interests;
   4. Job role and other company information
   5. IP address (automatically collected);
   6. web browser type and version (automatically collected);
   7. operating system (automatically collected);
   8. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

in each case, in accordance with this privacy policy.

How we collect Data

7. We collect Data in the following ways:
   1. data is given to us by you,
   2. data is collected automatically,
   3. data is collected manually.

Data that is given to us by you

8. Larato Limited will collect your Data directly in a number of ways, for example:
   1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
   2. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
   3. when you elect to receive marketing communications from us; in each case, in accordance with this privacy policy.

Data that is collected automatically

9. To the extent that you access the Website, we will collect your Data automatically, for example:
10. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
11. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Data that is collected manually

10. Larato Limited may collect your Data indirectly as we collect publicly available information from across the web.

Our use of Data

11. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience. Specifically, Data may be used by us for the following reasons:
    1. internal record keeping;
    2. transmission by email of marketing materials that may be of interest to you;
    3. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
    4. collected data may be held in our Inside Track database. Please note this does not include any personal information.

in each case, in accordance with this privacy policy.

12. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests, which include;
13. Providing and improving our services,
14. Conducting business development activities,
15. Communicating with you effectively,
16. Protecting our business operations and security.

If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).”

13. For the delivery of direct marketing to you via e-mail, we operate within the below laws and acts:
    1. Larato conducts direct marketing campaigns within the guidance of the Data Protection Act 2018, s.122(5).  The protection of personal data and the delivery of marketing by email are governed in the United Kingdom by separate but related laws. In addition to data protection legislation such as the UK GDPR and Data Protection Act 2018, The Privacy and Electronic Communications (EC Directive) Regulations 2003, also known as “PECR”, is the principal law that covers direct marketing by email.  In terms of the PECR, the subscriber is the individual or legal entity that is party to a contract with a provider of public electronic communications services. It specifically defines a corporate subscriber as, essentially, an incorporated company. This is different from the usual meaning of “subscriber” when discussing mailing lists. ICO guidance clarifies that this includes public bodies and Scottish partnerships, but not sole traders or members of an ordinary partnership, as they are not incorporated. In terms of email, the subscriber is held to be the individual or organisation for whom the email service is operated. Any of a corporate subscriber’s email addresses would be a corporate email address. If a corporate email address contains a person’s name or distinctive job title, it is known as a personal corporate email address. This is not the same as a strictly personal email address pertaining only to a private individual. Regulation 22 prohibits the delivery of unsolicited marketing messages by email to “individual subscribers”, with certain exemptions such as for existing customers. However, this does not apply to corporate subscribers. The UK’s data protection supervisory authority, the Information Commissioner’s Office or ICO, has published guidance clarifying that consent is not required to email business email addresses. Therefore, if your email address is identified as pertaining to a “corporate subscriber” within the meaning of PECR Regulation 2, we will contact you in line with the above guidance. Data protection laws still apply to any personal data being stored or used in relation to that address, such as if your email address contains your name, or a job title through which you could be easily identified. Such personal data is lawfully processed under Art. 6(1)(f) of the UK GDPR.
    2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
    3. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.

Who we share Data with

14. We may share your Data with the following groups of people for the following reasons:
    1. our employees, agents and/or professional advisors – in order to effectively direct marketing communications;

in each case, in accordance with this privacy policy.

Keeping Data secure

15. We will use technical and organisational measures to safeguard your Data
16. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: privacy@larato.co.uk.
17. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

18. We will retain your data for as long as necessary to provide services or as required by law. Factors we consider when determining retention periods include legal obligations, the nature of our relationship with you, and ongoing business needs. You have the right to request the erasure of your data in certain circumstances (see the section headed “Your rights” below).”
19. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

20. You have the following rights in relation to your Data: 
    1. Right to access– the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct– the right to have your Data rectified if it is inaccurate or incomplete.
    3. Right to erase– the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data– the right to “block” us from using your Data or limit the way in which we can use it.
    5. Right to data portability– the right to request that we move, copy or transfer your Data.
    6. Right to object– the right to object to our use of your Data including where we use it for our legitimate interests.

20. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: privacy@larato.co.uk.
21. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
22. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Changes of business ownership and control

24. Larato Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Larato Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
25. We may also disclose Data to a prospective purchaser of our business or any part of it.
26. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

27. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
28. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
29. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
30. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this Privacy Policy

31. Larato Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact Larato Limited by email at privacy@larato.co.uk

This privacy policy was last updated October 2024.